On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
1/6/2020
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Final Rules ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Foreign Banks ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Interest Payments ,
IRS ,
Multinationals ,
New Rules ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns ,
Taxable Distributions ,
U.S. Treasury
On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more